Compliance for Background Checks and QRIS Delayed until September 2019

Office of Head Start (OHS) recently announced an update which will delay compliance requirements for background checks and the Quality Rating and Improvement Systems (QRIS) until September 30, 2019. Under the initial rule, programs were required to comply by September 2017, which was delayed until September 2018. The summary from the updated rule reads:

“The Office of Head Start will further delay the compliance date for programs to meet background checks requirements and participate in their state or local Quality Rating and Improvement Systems (QRIS). The Department delayed the compliance dates for these standards through a previous document in the Federal Register. Since then, we have learned programs could benefit from more time as they work to align with state systems to meet these federal standards.”

Since programs have another year to comply with these requirements, we thought we’d take some time to talk about the requirements for background checks and QRIS, so that programs can make sure they’re on the right track to compliance in 2019.

Background Checks

In Head Start Policy & Regulations 45 CFR § 1302.90(b), it outlines the requirements for background checks on potential new personnel. In delaying the requirement, OHS was particularly concerned about the additional time required to work in conjunction with local, state, and federal law enforcement systems.

The policy states that programs must obtain one of two records for new personnel: State or tribal criminal history records, including fingerprint checks; or, Federal Bureau of Investigation criminal history records, including fingerprint checks. In addition, agencies must obtain a child abuse and neglect state registry check, if available, within 90 days of employment.

The delayed rule states: “We believe programs require more time to implement systems to complete the background checks process… We aligned our compliance date for our background checks requirements with the background check requirement deadline the CCDBG Act (see: Child Care and Development Block Grant (CCDBG) Act of 2014) because states that receive CCDBG funds are required to establish systems that implement the same set of comprehensive background checks for all child care teachers and staff. These systems will enable Head Start programs to meet background check requirements in the final rule.”

Quality Rating and Improvement Systems (QRIS)

Head Start doesn’t want to exist in a vacuum. The purpose of this requirement is to make sure that the federally-funded program, with the exception of American Indian and Alaska Native programs, is also meeting state quality standards for early childhood education (45 CFR § 1302.53(b)(2)).

From the rule: “A QRIS is a systemic approach to assess, improve, and communicate the level of quality in early and school-age care and education programs within a state or locality. It awards quality ratings to programs that meet a set of criteria as defined by the QRIS. Criteria Head Start programs must meet to enter the QRIS and maintain participation greatly vary by state.” (View your state profile at this link.)

With participation in the QRIS from Head Start, OHS recognizes that both states and programs will need more time to align their systems:

“We want to minimize any unintentional burden on states that choose to adapt their systems to allow Head Start programs to participate in QRIS, as well as alleviate programs’ concerns about meeting the current compliance date. To avoid duplication efforts between Head Start and QRIS monitoring systems as well as eliminate undue burden on Head Start programs and states as they work to align these systems, we will delay the compliance date for this standard for another year.”